Hazardous Waste: the usual suspects and how to manage them

Transcription

1 Hazardous Waste: the usual suspects and how to manage them P R E S E N T E D B Y : R O L A N D J. F O R N O F F S O U T H E R N N E V A D A S U S T A I N A B I L I T Y M A N A G E R

2 Hazardous waste you say?

3 However

4 Businesses Generating Haz. Waste Hotels Casinos Automotive shops Golf courses Manufacturers Printers Dry cleaners Painters & construction contractors Retail centers Laboratories Hospitals Furniture repair Cabinet makers

5 Recognize These?

6 RCRA Hazardous Waste

7 WHAT IS RCRA? Resource Conservation and Recovery Act Passed by Congress in Federal regulation that establishes Cradle to Grave management requirements for hazardous waste. RCRA waste = federally identified hazardous waste

8 Pre-regulation (<1976) Haz. Waste Disposal

9 Pre-regulation (<1976) Haz. Waste Disposal

10 With Cradle to Grave Management

11 Elements of Haz. Waste Management Waste Determination Generator Status On-Site Management Spill Response Record Keeping

12 Haz. Material or Haz. Waste?

13 What is Hazardous Waste? A hazardous waste is a material destined for treatment, disposal or recycling with properties that make it dangerous or potentially harmful to human health or the environment. Hazardous wastes can be liquids, solids, compressed gases, or sludges. They can be the by-products of manufacturing processes, off-spec commercial products, or other discarded articles or wastes.

14 MAKING A WASTE DETERMINATION CFR 40, Sections Characteristics Of Hazardous Waste CFR 40, Sections Listed Hazardous Waste At The Point of Generation You are LEGALLY RESPONSIBLE for ALL hazardous wastes generated!!!

15 Tools for Making a Waste Determination Material Safety Data Sheets (MSDS) Product Manufacturer Process Knowledge Environmental Laboratories Your state or local environmental business assistance program

16 Is It A Hazardous Waste? Four Questions to ask: Is it a solid waste? Is it exempt or excluded? Is it listed? Is it characteristic? Asking these questions should keep mistakes in identifying hazardous waste to a minimum. (40 CFR ).

17 Identify if the Waste is a Solid Waste A Solid Waste may be a Solid, Liquid, or Gas. A material is a solid waste if it is Discarded : Abandoned; Disposed of; Recycled; Burned or incinerated. A material must be a Solid Waste before it can be a Hazardous Waste.

18 If you answer NO to question #1 Stop!! You do not have a hazardous waste!

19 Exclusions/Exempt Domestic sewage Industrial wastewaters covered under the clean water act Irrigation return flows Household hazardous waste See 40 CFR for complete list

20 Waste Determination Now determine if the waste is: Listed? Characteristic? Both Listed & Characteristic? Keep All Determinations on File Even if the waste is non-hazardous

21 Is it Listed? F LIST - wastes from non-specific sources such as solvents, still bottoms, and plating wastes K LIST specific wastes from the chemical manufacturing industry P, U LISTS discarded and/or, off-spec chemical products, container residues and spill residues P - ACUTE HAZARDOUS WASTE U - TOXIC HAZARDOUS WASTE

22 4 Hazardous Characteristics A hazardous waste can be defined by one or more of the following: Ignitability = D001 Corrosivity = D002 Reactivity = D003 Toxicity = D004 D043

23 Ignitability - D001 The flashpoint is < 140º F (60º C). Common wastes include: Paint thinner Gasoline Alcohol Solvents Flammable compressed gas

24 Corrosivity - D002 It is an aqueous solution with a ph of 2 or Hydrochloric acid, Sodium hydroxide It corrodes steel at 6.35 mm/year at 55º C. Common examples include: Waste from rust remover Alkaline cleaning fluid Battery acid

25 Reactivity - D003 Normally unstable, explosive, reacts violently with water or forms toxic gasses Cyanide or sulfide bearing waste when exposed to ph conditions between 2 and 12.5 can generate toxic gasses Capable of explosion or detonation Examples include: waste from cyanide plating, bleach

26 To icity - D004-D043 Regulatory levels are based on ability to leach to groundwater. Laboratory Analysis assesses concentration in sample (TCLP Test)

27 TCLP Testing Measures the potential to seep or "leach" into groundwater if a waste is landfill disposed 40 parameters, specific regulatory limit for each Must be done by a certified lab Examples from the 40 CFR Table 1 EPA HW Code Contaminant Regulatory Level D018 Benzene 0.5 mg/l D008 Lead 5.0 mg/l D009 Mercury 0.2 mg/l D035 Methyl Ethyl Ketone (MEK) 200 mg/l D039 Tetrachloroethylene 0.5 mg/l D043 Vinyl Chloride 0.2 mg/l

28 Wastes Typically Needing TCLP Paint Booth Exhaust Filters Sand/Oil Separator Sludge Solvents Paints High-Flash Or Aqueous Cleaning & Degreasing Solutions

29 Common Hazardous Wastes

30 Common Violation Failure to make a waste determination Business doesn t determine if waste is hazardous or non-hazardous No supporting documentation

31 Special Waste Streams E-Waste Universal Waste Wipers and Rags Used Anti-Freeze Used Oil

32 E-Waste

33 Electronic Waste AKA E-waste: Electronic equipment and products that are broken, obsolete, discarded or have reached the end of their useful life. Computer and Video Monitor glass typically contains enough lead to be classified as hazardous waste. Printed wiring boards contain plastic and copper, plus chromium, lead solder, nickel, and zinc.

34 E- Waste Management Most electronics- computers, keyboards, stereos, etc. are exempt if recycled for scrap metal. Intact CRT monitors may be shipped to a recycling facility If the monitor is broken (i.e. vacuum released), it MUST be managed as hazardous waste.

35 Universal Waste Streamlines collection and management standards for certain hazardous waste streams: Used fluorescent, neon, mercury vapor, sodium, and HID lamps. Batteries; Recalled/suspended pesticides; Mercury-containing equipment.

36 Universal Waste Intent is to encourage recycling. Does not count toward generator status. Shows attempt to reduce the volume and toxicity of hazardous waste.

37 Universal Waste Requirements Small Quantity Handlers of Universal Waste: Accumulates less than 5,000 kg (11,000 lbs.) at any time; No EPA ID Number Required; Compatible closed container; Proper labeling: start date and UNIVERSAL WASTE- BATTERIES, - LAMPS, etc.; 1 year storage limit from start date; No manifesting or paperwork retention requirements; Employee training.

38 Improper Universal Waste Storage

39 Improper Universal Waste Storage

40 Improper Universal Waste Storage BROKEN fluorescent bulbs, batteries, mercury-devices need to be managed as Hazardous Waste - NOT Universal Waste

41 Proper Universal Waste Storage

42 Mercury Containing Equipment

43 Storing Mercury Containing Equipment

44 Batteries

45 Batteries If picked up for recycling, not considered hazardous waste. Keep receipts on file to document recycling. If cracked, prepare a waste determination prior to disposal (D002, D008). Tape terminals if possible to prevent contact Remember to store in a cool, dry, and safe place!

46 Improper Battery Storage

47 Proper Battery Storage

48 Other/Exempt Wastes Streams Specific types of waste are not regulated as hazardous waste provided that they are managed properly. Examples include: Wipers and Rags. Used Antifreeze; Used Oil; Oil Filters;

49 Wipers and Rags If disposed, you must determine if they are hazardous waste: Listed solvents; Toxic characteristics.

50 Wipers and Rags Wipers and Rags professionally laundered for reuse at a permitted facility are considered non-hazardous if: No Free Liquids; Managed in Closed Containers; Labeled.

51 Used Antifreeze If recycled, no waste determination needed. Does not count toward generator status. Keep receipts for at least 3 years. High volume users- consider recycling yourself.

52 Used Oil Label as Used Oil. Do not mix with hazardous waste. If recycled, it does not count toward generator status.

53 Used Oil Filters Exempt from hazardous waste regulation if the filters have been gravity hot-drained by any of the following methods: Puncturing the filter anti-drain back valve or filter dome and hot-draining; Hot-draining and crushing; Dismantling and hot-draining; or Any other equivalent hot-draining method.

54 Don t Forget these Waste Streams May be hazardous and require waste determination: Aerosol Cans; Filters; Machine Oils.

55 Generator Status Conditionally Exempt Small Quantity Generators (CESQG): less than 100 kg (220 lbs.) per month Small Quantity Generators (SQG): 100 kg or (220 lbs.) but less than 1,000 kg (2,200 lbs.) per month. Large Quantity Generators (LQG): more 1,000 kg (2,200 lbs.) per month.

56 Generator Status Cumulative of all hazardous wastes generated per calendar month and accumulated on site at any one time. Cannot Average generation over the year Waste that is stored prior to recycling is counted toward generator status. Change in status, facility must be managed as such.

57 Disposal Matrix Category Conditionally -Exempt Small Quantity Generator (CESQG) Generation Limit < 100 kg/mo (less than 220 lbs) of hazardous waste <1kg/mo (2.2 lbs) of acutely hazardous waste Storage Time None none Storage Quantity 1,000 kg (2,200 lbs) of hazardous waste 1 kg (2.2 lbs) of acutely hazardous waste Requirements if Limit(s) are Exceeded If generator exceeds generation limit, waste is subject to LQG or SQG requirements depending upon amount exceeded If generator exceeds storage quantity limit, waste is subject to SQG requirements. If generator exceeds generation limit, waste is subject to LQG requirements. Small Quantity Generator (SQG) Large Quantity Generator (LQG) 100 to 1,000 kg/mo (220-2,200 lbs) of hazardous waste >1,000 kg/mo (2,200 lbs) of hazardous waste >1kg/mo of acutely hazardous waste 180 days (or 270 days if waste must be shipped over 200 miles) 6,000 kg (13,200 lbs) of hazardous waste If generator exceeds generation limit, waste is subject to LQG requirements If generator exceeds storage time or quantity limits. Facility is subject to storage facility (TSD) requirements 90 days None If generator exceeds time limit. Facility is subject to storage facility (TSD) requirements. 100kg = 220 lbs. or approximately 26 gallons

58 Federal EPA ID Numbers NVR : All SQG and LQG are required to have an EPA ID Number. CESQG Not required, typically. CESQG Disposing of hazardous waste in other states may be required to obtain an EPA ID number.

59 Federal EPA ID Numbers To apply for the EPA ID #: Complete form Notification of Regulated Waste Activity and mail to the appropriate office for your state; Form available at ta/form8700/ pdf

60 Storage Requirements Proper Containers. Satellite Accumulation. Labeling. Central Accumulation Area. Inspections.

61 Hazardous Waste Containers Must Be: In good condition Compatible with the waste Always kept closed Labeled properly

62 Good Condition?

63 Common Violation Open Containers Securely Closed unless waste is being added or removed Only open when adding or emptying. Funnels in drums does not mean they are closed!

64 Empty?

65 Empty Containers Empty Containers: Good faith effort (all the material that can be removed has been removed); Less than 1 inch of residue or 3% or less by weight of total capacity; If P listed must be triple rinsed. A sewer permit is required for discharge to the sewer.

66 Containers Must be Labeled Clearly! Label must include: The words Hazardous Waste ; Description of contents; EPA Waste Codes; Beginning Date of Accumulation.

67 Satellite Accumulation CESQGs & SQGs may co-locate Satellite Containers with Central Storage LQGs must justify At or Near the point of generation, AND Under the control of the process operator Up to 55 gallons of hazardous waste or 1 quart acutely hazardous waste.

68 Satellite Accumulation Area Mark or label the container with the words Hazardous Waste, and/or other words that identify the content of the containers. Within 3 days of the container becoming full: Date EPA Waste Code Transfer to central storage

69 Common Violations 90 or 180 day storage area vs. satellite area Labeling Violations Wording Accumulation start date

70 Container Staging

71 Central Accumulation Area Containers handled so they will not rupture or leak. Access control. Containment. Waste segregated if incompatible. Protect containers from elements.

72 Accumulation Time Limits CESQG - cannot store more than 1,000 kg (2,200 lbs) at any time or more than 1kg (2.2 lbs) of acutely hazardous waste SQG days or 270 days if waste is shipped greater than 200 miles away LQG - 90 days

73 Container Inspections SQG and LQG required to inspect the hazardous waste storage area weekly. Inspections must note: Date and Time of Inspection; Name of Inspector (Signature); Observations made; Date and Time of any corrective actions. Maintain written records of inspections for at least 3 years.

74 Nothin Fancy

75 2012 Hazardous Waste Compliance Calendar ASSISTING NEVADA BUSINESSES WITH ENVIRONMENTAL MANAGEMENT AND ENERGY EFFICIENCY ISSUES (800) This calendar was developed by the Business Environmental Program.

76

77 Common Violation Weekly Inspections (SQGs & LQGs) Must inspect weekly Must maintain log Date & time Inspector name Observations Remedial action taken

78 Preparedness and Prevention Emergency Coordinator. Spill Response. Preparedness and Prevention Plan (P3) Training.

79 Emergency Coordinator One or more employees designated to coordinate emergency response measures Must post next to telephone: Name and phone numbers of coordinators; Location of fire extinguishers, spill control equipment; Location of alarm system (if present); Phone number of Fire Department.

80 Spill Response HAVE A SPILL KIT STOCKED AND READY! Employees familiar with waste handling and emergency procedures. Make sure employees are able to respond in the event of an emergency.

81 Preparedness and Prevention Plan (P3) Required for SQG and LQG: Maintenance and operation of facility; Required equipment; Testing and maintenance of equipment; Access to communications and alarm systems; Required aisle space; Arrangements with local authorities.

82 Required Equipment All facilities are required to have: Internal communications or alarm system (voice or signal); (i.e. a telephone or two way radio), Portable fire extinguishers; Spill control equipment; Decontamination equipment (if required); and Water in adequate volume and pressure.

83 Testing and Maintenance All facility communications, fire protection equipment, spill response equipment (if required) must be tested and maintained as necessary to assure proper operation.

84 Communications/Alarm System Whenever hazardous waste is being handled, persons involved must have immediate access to: An internal alarm; or Emergency communication device. If there is just one employee on the premises while the facility is operating he/she must have a cellular phone or two-way radio to summon help.

85 Required Aisle Space Adequate aisle space is required to allow unobstructed movement of personnel, fire protection equipment or decontamination equipment (if required) to any area of the facility in the event of an emergency. 40 CFR

86 Arrangements with Authorities Familiarize police, fire department, and emergency response teams with: The layout of the facility; Properties of the hazardous waste and associated hazards; Places where employees work; Possible evacuation routed; Have proof of notification to local authorities.

87 Arrangements with Authorities Familiarize local hospitals with: Waste types handled at the facility; Types of injuries and illness that could result from handling or exposure to the waste either through handling or fire or explosion; If either State or Local authorities decline to enter into such arrangements the refusal must be documented into the facility operating record.

88 Employee Training SQG facilities must ensure all employees are familiar with: Proper waste handling procedures; and Emergency procedures. Spill response Evacuation plan Fire extinguisher location Decontamination procedures (if necessary)

89 Common Violation Training Inadequate employee training Not documenting employee training

90 Manifests

91 Manifests Must be used by all SQG and LQGs that ship hazardous waste off-site for treatment, storage, disposal, or recycling. Provides tracking from your facility to TSDF Generator initiates the manifest TSDF sends signed copy back to generator Staple signed copy to the original; not required, but helps to keep them organized. Keep on file for 3 years. Used to complete the Biennial Hazardous Waste Report

92 Biennial Generator Reports (BGR) Due March 1, 2014 Federally required by all LQGs and TSDFs; some states require reports from SQGs and CESQGs.

93 Recordkeeping Operational Records: Waste Determination; Training Records; Weekly Inspection Records. Waste Disposal Records: Manifests; Land Disposal Restrictions; Tolling Agreements. Preparedness and Prevention Records: Preparedness and Prevention Plan; Contingency Plan; Required Postings.

94 What are My Basic Responsibilities as a Hazardous Waste Generator? Follow procedures for labeling, storing and disposing of hazardous waste. Maintain proper records and paperwork. Prepare ahead of time for spills or other mishaps. Minimize the amount of waste generated.

95 Pollution Prevention (P2) and Waste Minimization Primo Levi

96 Emissions Input Materials Process Product Waste

97 Pollution Prevention Pollution Control Input Materials Process Product Waste

98 BENEFITS OF P2 Improved worker health and safety Minimize exposure to hazardous products Improved training leads to safer work practices

99 BENEFITS OF P2 Environmental Protection Cleaner air and water Conserve natural resources Reduce pollutants entering the environment

100 BENEFITS OF P2 Cost Savings Savings in material, supply, and tracking costs Reduced liability and regulatory burden Elimination of expensive clean-up costs

101 SEVEN P2 TECHNIQUES Policy/Procedural Change Equipment Modification Material Reuse Material Substitution Process Efficiency Improvements Improved Housekeeping Inventory Controls

102 POLICY or PROCEDURAL CHANGE Technique 1 Put policy in place requiring the purchase of less hazardous products or the use of less wasteful practices. -Require metal free auto paint -Low VOC latex paint -Double-sided printing

103 Equipment Modification Replacing solvent degreasers with aqueous parts washers. Technique 2

104 Equipment Modification Technique 2 Digital Photography/ X-Ray

105 Equipment Mod./ Material Reuse Using a distillation/recovery unit allows you to reuse the product and reduce your waste quantities, saving costs on purchasing and disposal. Technique 2 and 3

106 Case Study Aggregate Industries - Las Vegas, NV Purchased 125 gallons of solvent each month; generated 125 gallons of hazardous waste solvent per month. Product purchase and waste disposal cost: $40,000 per year Purchased a solvent recovery unit for $4,500. Reduced hazardous waste generation by 9,500 lbs per year Annual savings $34,000

107 MATERIAL SUBSTITUTION Purchase Environmentally Preferable Products Technique 4

108 MATERIAL SUBSTITUTION Replace aerosol solvents with compressed air sprayers and citrus-based cleaners for cleaning and degreasing. Technique 4

109 PROCESS EFFICIENCY IMPROVEMENTS Laser guide for spray gun Technique 5

110 IMPROVED HOUSEKEEPING Technique 6 Preventative maintenance Proper labels Organization Keep lids closed Reduced opportunities for accidents

111 INVENTORY CONTROLS The hazardous material barcode color changes every year. Technique 7 Barcode# Year Barcoded 1A A A

112 WASTE MINIMIZATION/P2 WRAP-UP Purchase less hazardous material. Use it more efficiently. Reduce waste management cost. Reduce insurance costs. Reduce labor, recordkeeping, reporting and regulatory requirements. Feel good and make more money.

113 Roland J. Fornoff Southern Nevada Sustainability Manager